Sunday, November 17, 2013

People v. Rodriguez case brief

People v. Rodriguez case brief summary
8 Cal. Rptr. 863 (1960)

Defendant was found guilty by the Superior Court of Los Angeles County (California) of involuntary manslaughter for the death of her minor child in a fire. A new trial was denied. Defendant appealed from the judgment and the order denying a new trial.

Defendant's home caught on fire with her children inside and a baby boy died. Defendant was not at home at the time of the fire. The trial court found defendant guilty of involuntary manslaughter.


  • On appeal, the court reversed, holding that the evidence failed to establish that defendant had the knowledge, actual or imputed, that her actions tended to endanger life and that the fatal consequences of the negligent act could reasonably have been foreseen. 
  • The court found that the only reasonable view of the evidence was that the death of the baby was the result of misadventure and not the natural and probable result of a criminally negligent act. 
  • There was no evidence that defendant realized her conduct would have in all probability produced death. 
  • There was also no evidence as to the cause of the fire or connecting defendant in any way with the fire. 
  • There was no evidence that defendant could reasonably have foreseen there was a probability that fire would ignite in the house and that the baby would have been burned to death. 
  • The court ruled that, although defendant might have negligent, mere negligence was not sufficient to authorize a conviction of involuntary manslaughter.

The court reversed the judgment of the trial court finding defendant guilty of involuntary manslaughter and reversed the order denying a new trial.

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